The recent public revelations surrounding HSBC’s questionable and unethical behavior has caused regulators to shift their attention to individual employees— especially those in the banking giant’s compliance department and the executives who approved the due diligence of certain acquisitions.

According to a recent Financial Times article, HSBC’s senior executives, Group Chairman Douglas Flint and Chief Executive Stuart Gulliver, have been under scrutiny by regulators since the International Consortium of Investigative Journalists obtained “secret documents” stating that HSBC’s Swiss private banking arm failed to conduct sufficient due diligence on some of its clients who engaged in illegal activities while committing tax fraud. This points to the question: which executive will be held more accountable for these compliance and control failures?

“Douglas has got more trouble on his plate than Stuart,” the Financial Times article points out. “He was the executive responsible for risk, compliance and as finance director he signed off on all of these acquisitions. He’s been there at every misstep. Douglas would also fall on his sword if necessary in a way that Stuart wouldn’t.”

Over the years, Flint carved out a name for himself at HSBC. He led a host of acquisitions, which allowed the bank to become one of the world’s largest by assets.

Now news reports indicate that the due diligence process in three of Flint’s major deals were recently called into question. The most recent under scrutiny was its acquisition of Republic New York Corp. and Safra Republic Holdings in 1999, which formed most of HSBC’s private banking operations that later triggered a string of scandals.